The first updates to the COPPA Rule since 2013 impose new obligations for sharing children’s personal information with third parties.
By Jennifer C. Archie, Marissa R. Boynton, Michael H. Rubin, Molly O’Malley Clarke, and Elizabeth Yin
On April 22, 2025, the Federal Trade Commission (FTC or Commission) published the final amendments to the Children’s Online Privacy Protection Rule (COPPA Rule)1 in the Federal Register. The published amendments will become effective on June 23, 2025, and operators will have until April 22, 2026, to come into full compliance (except for FTC-approved COPPA safe harbor programs, which must comply with certain amendments that specify earlier compliance dates).
The FTC issued a Notice of Proposed Rulemaking (Notice) on December 20, 2023 (summarized in this Client Alert), recommending revisions to amend certain definitions (including “personal information” and “website or online service directed to children”). The Notice also included recommendations to clarify the COPPA Rule’s application to education technology and implement new restrictions on the use and disclosure of children’s personal information, including a separate parental consent requirement for disclosures to third parties.
On January 16, 2025, after receiving about 300 comments in response to the Notice, the FTC accepted most of the Notice’s proposed amendments and unanimously agreed 5-0 to publish the final amendments (Final Rule). The Commission stated that these amendments, the first updates to the COPPA Rule since 2013, were prompted by changes in how children use online services.
Our Client Alert summarizes key updates from the Final Rule and the proposed changes that the FTC declined to adopt.
- Children’s Online Privacy Protection Rule, 64 Fed. Reg. 16918 (April 22, 2025) (codified at 16 C.F.R. Part 312). ↩︎